MedTech – Eisner Safety Consultants

EN 60601-1 Harmonised, and “EC REP” Becomes “EU REP”: Annex ZZ, State of the Art, and the MDR Questions the Headlines Skipped

leoeisner — Tue, 30 Jun 2026 22:50:00 +0000

After the Official Journal harmonised EN 60601-1 on 17 June 2026, I later wrote up an overview: what changed, the nine-year wait, what to cite, and the EC REP to EU REP switch riding alongside it. Then the comments started, and the good ones went straight past the headline. This is the deeper cut.

This post assumes you already know that EN 60601-1:2006/A13:2024 landed at entry No. 65 and that A13 carries Annex ZZ. From here I want to answer the questions my readers actually asked. I have deliberately not repeated much of what is already in the LinkedIn article, which covers the background, the full decision, and several points I do not revisit here, so it is worth reading alongside this.

The nine-year road from the MDR to entry 65.

Resources for this post

What a presumption of conformity really buys you

Here is the sentence people skip: a harmonised standard gives you a presumption of conformity only for the requirements Annex ZZ says it covers. Not the whole of Annex I. Not “the device is compliant.” Just the specific General Safety and Performance Requirements (GSPRs) the table maps.

Annex ZZ is formally informative. It was prepared under mandate M/575 as one voluntary means of conforming, and it spells out the mechanism: once the standard is cited in the Official Journal, compliance with the normative clauses in its Table ZZ.1 confers a presumption of conformity, but only within the scope of the standard.

Look at Table ZZ.1 itself, the mapping table inside Annex ZZ, and its limits jump out. In its “Remarks / Notes” column, coverage is stated again and again as basic safety and essential performance within the scope of the EN, not the whole of a requirement. Whole categories come back “not covered” or only “partly covered,” because 60601-1 addresses them only by pointing to other standards: biocompatibility, EMC, usability, and sterilization all fall into that bucket. The standard says so in its own notes: if a GSPR is not in Table ZZ.1, it is not addressed here.

Annex ZZ also carries Table ZZ.2, the terms where the MDR definition prevails over the standard’s. “Harm” in the standard reaches property and the environment; under the MDR it narrows to people. “Patient” means human use only under the MDR, whereas in the EN it has always included animals and will continue to do so in the 4th edition. “Risk management” as the MDR uses it is broader, so the standard’s coverage of it is correspondingly limited. A reviewer reads your file against the regulation’s vocabulary, not the standard’s.

So the real work is not “we cite the harmonised standard, therefore we are covered.” Run it as a gap analysis: lay every Annex I GSPR as a row; for each one Annex ZZ maps, record the clause and copy any partial-coverage qualifier word for word; for the GSPRs 60601-1 does not touch (biocompatibility, EMC, sterilization, much of usability, clinical, labelling content), name the other standard, test, or risk-file evidence that carries it; and flag anything leaning on an older or non-harmonised source before a reviewer does.

Two Z-annexes, two different jobs: do not confuse ZA with ZZ

While everyone talks about Annex ZZ, do not walk past Annex ZA. They look alike and do completely different things.

Annex ZZ (informative by designation, but the mechanism the Official Journal citation activates) maps the standard’s clauses to the MDR GSPRs and supports the presumption of conformity. Annex ZA is the normative references table: it lists every IEC and ISO publication the standard depends on and gives the corresponding European (EN/HD) version. Being normative, those references are part of the requirements.

Annex ZA carries two rules that quietly decide what you must meet. First, dated versus undated references: for a dated reference only the cited edition applies; for an undated one the latest edition, including amendments, applies, so it moves under your feet over time. Second, “(mod)” means the international text was changed by European common modifications and the EN/HD applies, not the plain IEC or ISO version.

The Z-annexes for the EN 60601 and EN 80601 series standards are drafted by CENELEC, in TC 62 WG 2 for medical devices. The members of that committee have written a guide titled the “Cookbook” for writing harmonised standards under the MDR and IVDR. Beat Keller, one of my ESC experts, is a member of that committee. The cookbook exists to give the writers of these harmonised European standards practical, consistent ways to handle the European forewords and the Z-annexes, and in particular to resolve the issues raised during HAS consultant assessments of draft standards. It is not a minor internal note either: the European Commission’s DG SANTE and the MDCG standards subgroup judged its first edition “in principle complete and ready for use” back in November 2022, which made it a solid basis for writing the harmonised standards in this series and their annexes.

“Harmonised” is not the same as “state of the art”

One of the sharpest points from the comments is worth making loudly: presumption of conformity and state of the art are two different tests, and passing one does not pass the other.

A harmonised standard, applied in scope, gives presumption of conformity for the GSPRs it covers. State of the art is a separate expectation running through the MDR’s GSPRs in Annex I, and it is not defined in the regulation. In practice the newest recognised edition is treated as the state of the art, even when that edition is not the harmonised one. So the version that gives you the presumption can be older than the version that represents the state of the art, and when they diverge you can be presumed conformant and still be expected to show how you meet the current state of the art.

A concrete example sits inside this very decision. Before 17 June 2026, citing the older EN ISO 10993-23:2021 held a valid presumption, yet its 2025 amendment was already the newer state of the art. The same Decision (EU) 2026/1231 then harmonised the amended versions and set the old ones to be withdrawn from 15 December 2027. That lag is the normal rhythm, not a glitch: when a newer edition appears, assess it as potential state of the art even while you still cite the harmonised version for presumption.

And the citation question that came up in the comments now has a clear answer. For use under the MDR, cite the full amendment chain: EN 60601-1:2006+A1:2013+A12:2014+A2:2021+A13:2024, which corresponds to IEC 60601-1:2005+A1:2012+A2:2020 (Edition 3.2, with A13:2024 carrying Annex ZZ). That is how the standard designates itself on its own cover, and it is what belongs on your Declaration of Conformity and standards list. The clipped “EN 60601-1:2006/A13:2024” is fine for a headline, not for your technical documentation.

Legacy devices and the audit question

Now that 60601-1 is harmonised, will Notified Bodies scrutinise how legacy data lines up with it? First the framework. Legacy devices on valid MDD or AIMDD certificates under Article 120(3) of the MDR, as amended by Regulation (EU) 2023/607, may stay on the market to the 2027 or 2028 dates provided they keep conforming to their directive and undergo no significant change (MDCG 2020-3). They are not required to re-certify to a harmonised 60601-1. What continues to apply are the ongoing MDR obligations, including post-market surveillance, vigilance, and risk management.

So the new listing does not, by itself, force anything onto a legacy device. But once a current harmonised reference exists, it becomes the obvious yardstick, and reviewers reach for the obvious yardstick. For devices in MDR conformity assessment now, EN 60601-1:2006/A13:2024 is the reference to build against; for legacy devices, expect questions less about re-certifying and more about whether your risk management and post-market data still hold up against the current state of the art. Depending on what your risk management and any gap assessment turn up, that can, in some cases, push you toward a more current version of the standard.

The scope trap: your medical device might also be “machinery”

Here is one that quietly catches manufacturers, buried in the same Annex ZZ. Under Article 1(12) of the MDR, a medical device can also be machinery within the meaning of the EU Machinery Directive (2006/42/EC). When it is, certain Essential Health and Safety Requirements of that directive that are more specific than the MDR GSPRs apply on top of the MDR, and the standard maps them in Table ZZ.3.

In practice this bites devices with lifting parts or accessible non-manual moving parts: patient hoists, powered tables and chairs, motorised carriers. Two things people get wrong. First, Table ZZ.3 does not give you a presumption of conformity under the Machinery Directive and implies no Official Journal citation under it; it only maps where the machinery requirements are more specific. Second, the Machinery Directive is on its way out: Regulation (EU) 2023/1230 replaces it from 20 January 2027, so plan against the new Machinery Regulation, not the old Directive.

This is one of the most commonly missed corners of 60601-1 compliance, and untangling it is exactly the kind of scope work my team does. If your device lifts, rolls, or has powered moving parts an operator can reach, do not assume the MDR is the whole story.

Why “EC REP” existed in the first place

“EC” stands for European Community, the correct legal name until the Treaty of Lisbon replaced it with “European Union” in December 2009. So the “EC” in “EC REP” has been out of step with the Union’s own vocabulary for more than fifteen years. That is the whole reason for the move to “EU REP,” and it is why MDCG 2021-5 Rev. 1 can call it “purely editorial.” The generic symbol itself comes from EN ISO 15223-1: the standard defines an “XX REP” where “XX” is the ISO 3166-1 country code, and the Commission worked with the ISO working group to land on “EU” for the Union. The change did not appear from nowhere. It began as Amendment 2 to standardisation request M/575 (Commission decision C(2024)3371) in May 2024, when the Commission asked CEN and CENELEC to introduce “EU REP” and drop any reference to “European Community.” CEN and CENELEC accepted, ISO adopted the amendment, the EN amendment followed, and the reference was published in the Official Journal on 17 June 2026, harmonised under both the MDR (Decision (EU) 2026/1231) and the IVDR (Decision (EU) 2026/1313). So this is not a rename someone slipped in; it is a deliberate, traceable alignment of the symbol with the Union’s own legal language.

The change is editorial. The change control around it is not free.

The symbol change needs no prior Notified Body approval on its own, and you have five years of coexistence. All true. But “no approval needed” is not “free.” Labelling changes cost money and time no matter how small the wording, so most manufacturers batch the swap into the next artwork refresh. That is where the “editorial” framing bites: the moment you bundle EU REP with any change that is not editorial, you can pull the whole batch into Notified Body territory. Treat the five-year window as planning room, look at everything else riding in the cycle, and use the same pass to retire other “European Community” era wording, including any lingering “EC Declaration of Conformity.” It also helps to know how much room the MDCG actually gives you. During the five-year window both symbols are valid, and you may even carry “EC REP” and “EU REP” on different levels of the same packaging, with re-labelling or over-labelling accepted, as long as the authorised-representative information stays clear. Devices already on the market with “EC REP” before the deadline can continue to be made available. One date to put in your plan: the MDCG appendix and the IVDR decision give the end date as 17 June 2031, but the binding MDR text (Article 2 of Decision (EU) 2026/1231) deletes the old reference from 15 June 2031, two days earlier, so cite the binding date in your technical documentation.

The signal I care about most

Look past the individual entries and there is a bigger story. The harmonisation route for medical electrical standards had been stuck for years, and this decision is evidence that it is moving again. For those of us working on the IEC 60601-1, 4th edition, and the future of the series, that matters more than any single listing: a new edition is only as useful as its route to recognition. Entry 65 is one line in the Official Journal, but it tells me the door is open again.

The bottom line

Entry 65 was the easy part. The harder, more useful work is downstream: reading Annex ZZ for what it actually covers, holding presumption of conformity and state of the art as two separate tests, keeping legacy devices honest against a sharper yardstick, catching the machinery scope trap, and treating the “editorial” label change as a change-control decision. None of that fits in a post. That is why it lives here. And because this piece deliberately does not rehash the LinkedIn article, go back to it for the full decision and the details I did not repeat here.

Download the one-page cheat-sheet (PDF): entry 65, what to cite now, the EU REP dates, and official EU sources in one place.

Turn this into practical action

My team and I at Eisner Safety Consultants work with medical device, IVD, and combination product manufacturers to turn standards into practical design inputs, GSPR and gap analysis, labelling, test strategy, and technical documentation. That includes the machinery-scope questions many teams miss, and it is the kind of work we do every day. If any of this maps onto what your team is wrestling with, I would be glad to talk it through.

About Eisner Safety Consultants

Led by Leo Eisner, “The IEC 60601 Guy,” Eisner Safety Consultants helps medtech, IVD, and combination product companies design for and demonstrate compliance to the IEC 60601 and IEC 61010 series and, for drug-device combination products, ISO 11608 needle-based injection systems. We support design reviews, identification of applicable standards and regulations, GSPR and gap analysis, labelling reviews, and test-lab and regulatory strategy. See more about our team of experts at eisnersafety.com.

Keep the conversation going on LinkedIn

Read the full LinkedIn article: EN 60601-1 finally harmonised, and EN ISO 15223-1 ushers in “EU REP”.
See the LinkedIn launch post & comments: “Entry 65: The Last Line,” the announcement that kicked this off.

Reference materials (official EU sources)

Medical Device Compliance & Certification Summit – Why It Matters?

leoeisner — Tue, 23 Dec 2025 23:30:37 +0000

Medical Device Compliance & Certification Summit – Why It Matters?

Medical device and diagnostic compliance expectations are shifting earlier in the product lifecycle. IEC 60601 and related standards are no longer something teams can “handle at test.” Regulators increasingly expect standards interpretation, risk decisions, and test strategy to be visible and justified during design reviews and technical documentation development.

This shift is showing up in real ways – deeper design reviews, tougher pre-submission questions, and increased scrutiny of how standards were applied, not just whether a final test report exists.

To address this reality, Eisner Safety Consultants (ESC) is working with Nemko to deliver a three-day, in-person Medical Device Compliance & Certification Summit focused on how standards, testing, and regulator expectations intersect in real programs.

A focused, three-day program for engineering, regulatory, and compliance teams navigating IEC 60601, IEC 61010, EMC and RF requirements, certification strategy, and regulator guidance documents across FDA, EU, and other markets.

In-Person Training & Live Workshops

February 2–4, 2026
Carlsbad Inn Beach Resort, 3075 Carlsbad Blvd, Carlsbad, CA 92008

Designed for teams preparing new medical devices or diagnostics for market, working through recurring EMC or RF failures, or tightening FDA or EU MDR technical documentation ahead of submission or surveillance review.

Registration Summit Details

Who this summit is designed for

Electrical, EMC, RF, and systems engineers
Regulatory affairs and quality professionals
Product and compliance managers
Medical device and diagnostic startups preparing first submissions
Teams facing test failures, redesigns, or certification delays

What attendees will learn

How regulators evaluate standards application, not just test outcomes
Future impacts of IEC 60601-1, 4th edition concepts on design controls
Essential Performance and its role in risk management and review discussions
How EMC and RF strategies influence certification timelines
When IEC 61010 applies to diagnostic and laboratory equipment
Cybersecurity expectations under FDA and EU MDR
How guidance documents shape FDA and EU technical file expectations

How Eisner Safety Consultants Can Help

As regulatory expectations increase, delays are often caused by unclear standards interpretation, weak traceability between design decisions and requirements, and technical documentation that does not explain why choices were made.

Eisner Safety Consultants works with medical device, diagnostics, and combination device manufacturers every day to translate IEC 60601, IEC 61010, and related standards into practical design inputs, defensible test strategies, and documentation that aligns with FDA, EU, and other regulator guidance documents.

Registration Summit Details

From Engineer To “The IEC 60601 Guy” – Project MedTech Podcast

leoeisner — Sun, 19 Oct 2025 00:04:30 +0000

Podcast Feature

From engineer to “The IEC 60601 Guy” — my story and practical tips

I joined Duane Mancini on the Project Medtech Podcast to share how I became known for IEC 60601, why the series is a roadmap you can follow, and what 4th Edition changes mean for design, QMS, and documentation.

Episode 235

Listen on Web Open Spotify

A quick personal note

Nobody starts at the top as “The IEC 60601 Guy.” My path ran through early days at NASA, many years in test labs, and deep work in standards committees. What stuck with me is simple — stay curious, do the work, and show the work. That’s how we turn a dense standard into a practical plan.

Key takeaways from the episode

On the Project Medtech Podcast with Duane Mancini, M. Sc., I shared my genesis story of how I became known as The “IEC 60601 Guy”. Duane asked me to give listeners a 101 course on the IEC 60601 series, and I explained how I strive to “de-Greek” or demystify the standard series, and gave a preview of the big shifts coming in 4th Edition.

The “big picture” structure of the general standard, collateral standards, and particular standards

How lifecycle standards (risk management, usability, software) compare to type test standards in the 60601 family

Tangible changes to watch in the upcoming 4th Edition: clearer alarm requirements and impacts on design, QMS, & documentation

Why leaning on experts (internal or external) is key to getting this right for the impacts of 4th Edition

My goal is to “de-Greek” the process and show that IEC 60601 can be a roadmap , not a riddle

Whether you’re new to standards or a seasoned MedTech veteran, this episode shows how to approach IEC 60601 as a roadmap you can follow, instead of a riddle you can never quite solve.

What peers said

“If you want to know more about IEC 60601, Leo is the resource to go to … I recommend this episode to everybody working with medical electrical equipment.”

— Beat Keller

“Great to see how you became such an expert … I hope your story inspires young professionals to invest in becoming experts themselves.”

— Ronald Boumans

“It’s amazing that you covered the difference between process and test standards — there’s still a lot of confusion out there.”

— Tibor Zechmeister

Continue the discussion on this topic on LinkedIn

How We Can Help

If your team needs help with the IEC 60601 Series, or mapping the 4th Edition into your design controls, QMS, labeling, or testing strategy, my team at Eisner Safety Consultants and I are ready to support you.

Schedule a call with me, Leo, the IEC 601 Guy

🎥 IEC 60601-1 4th Edition: Design Controls And QMS Impacts You Need To Know 📣📣

leoeisner — Mon, 25 Aug 2025 09:31:00 +0000

On August 15, 2025, I had the privilege of presenting the Impacts on IEC 60601-1, 4th Edition webinar as part of MLVx Friday In-Focus. The turnout was incredible, with more than 110 MedTech professionals from around the world joining. Startups, SMEs, large manufacturers, test labs, and regulators were all represented.

We unpacked the drivers and major changes in the upcoming 4th Edition, and the discussion didn’t stop when the webinar ended. Some of the most valuable insights came afterward in the LinkedIn conversations that followed.

See the replay post and comments here on LinkedIn
And the prior post: Major changes to IEC 60601-1, 4th Ed. are closer than you think

What the Industry Is Talking About

From the comments and follow-up conversations, four major themes stood out:

SME vs Large Corp Burden – Smaller companies worry the 4th Edition requirements could hit them harder than large corporations with more resources.
National & International Committee Involvement – Many are realizing that participating in standards development, even at the national level, gives manufacturers a seat at the table. Being involved internationally is even more powerful if you can swing it.
Rationale Behind Requirements – The Design Specification requires a rationale for each requirement of the standard. This is not fully addressed in Ed. 3.2, so the change should help improve industry understanding of the standard going forward.
Impacts on Design Controls, QMS, and Labeling – These changes are not just “paper exercises.” They will reshape how manufacturers approach design controls, QMS integration, and labeling processes across the entire product lifecycle.

Replay Video

If you missed the live session or want to revisit the details, here’s the full webinar replay:

Download the slides here

Why This Matters

As the IEC 601 Guy, I’ve been deeply involved in the development of IEC 60601-1, not just for this edition but also for the previous edition. The 4th Edition is shaping up to be one of the most impactful yet, especially in how it connects to design controls, supplier oversight, and QMS processes.

Conversations like these are important because they highlight the real-world concerns of manufacturers, regulators, and test labs. They help ensure implementation of the standard is proactive, not reactive.

How We Can Help

If your team needs help mapping these 4th Edition changes into your design controls, QMS, or testing strategy, my team at Eisner Safety Consultants and I are here to support you.

Schedule a call with me, Leo, the IEC 601 Guy. My team & I are here to support your needs.

Keep the Conversation Going

Standards only evolve when industry voices are active. I encourage you to:

Join the LinkedIn conversation: Replay post + comments
See the earlier discussion thread: Major changes to IEC 60601-1, 4th Ed. are closer than you think
Explore more insights on my blog: Standards Updates or see my previous Podcasts

Together, we can make sure these changes lead to safer devices, smoother regulatory pathways, and stronger compliance strategies.

Major changes to IEC 60601-1 are closer than you think

leoeisner — Fri, 15 Aug 2025 18:53:33 +0000

Once the 4th Edition is published, redesigns and QMS updates will be far more costly.

Direct insights from someone in the development of IEC 60601-1, 4th Edition

Get an insider’s view of the upcoming changes, their real-world impact, and how to prepare, from someone directly involved in developing the standard.

Event Recap – MLVx Friday In-Focus

On Friday, August 15, the MLVx Friday In-Focus with Sean Smith brought together Leonard (Leo) Eisner, The IEC 60601 Guy, and 110+ professionals from around the globe, including the UK, Romania, US, France, Switzerland, Germany, Finland, and Pakistan, representing medtech manufacturers, regulators, test houses, and standards developers.

We focused on the impact of IEC 60601-1, 4th Edition, the global standard that defines safety and essential performance for medical electrical equipment, and what’s coming that many companies are still not prepared for.

The highlight was an impromptu expert panel with leaders in risk management, software, cybersecurity, regulatory submissions, and combination devices. Together, we tackled questions from every angle, sharing real-world insights on design, testing, and compliance challenges. The discussion showed exactly what’s possible when top experts collaborate to help the industry prepare for disruptive change.

(Full presentation available for download at the bottom of this post.)

Unlock Your IEC 60601-1 Insider Advantage

Mitigate Risks: Spot disruptive changes early, prevent costly redesigns, and align documentation ahead of competitors
Accelerated Compliance: Seamlessly integrate evolving requirements into your development pipeline
Leadership Insight: The IEC 60601 Guy and our expert team track areas of interest for your organization based on draft documents
Behind Closed Doors: Access knowledge while it’s still being developed
Ready to Leap Ahead? Let’s turn this insider pipeline into your 4th Edition fast-track

+1-503-709-8328
EisnerSafety.com
Schedule a Free 30-Minute Web Meeting

If you missed the live session, this recap and presentation will help you understand what’s coming — and more importantly, how to prepare.

MLVx Impact of IEC 60601-1 4th Ed FINAL Vers 2025-08-15 compressed for website Download

🎩 Get your reviewer’s hat on – IEC 60601-1, 4th Edition Draft Fragments Have Dropped‼️ 🚀

leoeisner — Sat, 28 Jun 2025 01:09:39 +0000

Posted on LinkedIn June 19, 2025. Updated with extra blog content June 25, 2025.

Over the last two weeks – and with a Friday night (6/20/25 Geneva time – late) finale still to come – we’ve seen CD1s and CD2 (WG 47 ONLY) fly out for Fragments 5, 6, 7, 8, 10, 11, and 12 from WG 41 through WG 48, but for WG 45.

This is not just standards spring cleaning – these are foundational changes to the IEC 60601-1 General Standard, folding the Collateral standards into the core. If you have medical electrical equipment, medical electrical systems or software SaMD or SiMD you need to be aware of these changes. If you’re a manufacturer, test lab, trade association, Notified Body, Regulator or other interested party who owns a risk file… you need to review this.

These fragments cover hazards related to: • Electrical, mechanical, thermal, and fire • Software & PEMS (SaMD, SiMD, firmware, OS…) • EM Disturbance, wireless coexistence, ionizing radiation, and electromagnetic exposure (EMF)

The International comment deadlines start closing August 29th, with more due by September 12th. National deadlines close much sooner (does your summer holiday schedule conflict?)

Don’t wait for the FDIS – get involved now or get caught off guard later.

Read the full breakdown of all Working Groups, due dates, and what you should do now:

Here’s the who’s who of the Working Groups behind the fragments with CD1 to issue 20 July:

• WG 41 – PEMS (e.g., SaMD (Software as a medical device), SiMD (Software in a medical device), firmware, software, apps, OS, drivers) related hazards WG 41 link

• WG 42 – Electrical hazards WG 42 link

• WG 43 – Mechanical hazards WG 43 link

• WG 44 – Thermal and fire hazards WG 44 link

Other Fragments CD1s & CD2 have recently published – clock ticking to get your comments in:

• Fragment 11 – WG 47: Electromagnetic exposure hazards (not optical or ionizing but including SAR) WG 47 link CD2, closes 29 August

• Fragment 10 – WG 46: Ionizing radiation hazards WG 46 link CD1, closes 5 September

• Fragment 12 – WG 48: Electromagnetic disturbances (including wireless coexistence) WG 48 link CD1, closes 5 September

The early pack of CD1 Fragments released late last year

Fragments 1–4 and 11 from WG 37–40 & WG 47 were released as CD1 back on December 6, 2024, with comments closing February 28, 2025. You can still access them if you’re a National Committee member for SC62A or a WG participant. If not, consider joining — this is a major transformation, and early awareness = better preparation. Access link

Here’s a handy summary table of the IEC 60601 Fragments, their WG #s, their titles, the issue & close dates & more.

Who Should Be Reviewing

Design and Systems engineers
Risk management experts/leaders
Electrical & mechanical designers
Software designers (SaMD/SiMD, firmware, OS)
EMC/EMF compliance leads
Compliance engineers
Regulatory and quality teams
Usability & human factors engineers
Test labs
Trade Associations
Regulators
Notified Bodies
Other Interested Parties

What You Need to Do

Review the Drafts & the 4th ed. Design & Architecture Specs Now • Assign key experts by hazard/WG • Map against your design controls: Design Spec • Understand the architecture spec: Architecture Spec
Track IEV Part 880 Terms • Stay aligned with the evolving definitions: Terms & Definitions
Analyze Impact to Products • Run gap assessments • Identify implications for design, testing, and documentation
Submit Comments • Through your National Committees (ANSI, BSI, DIN, etc.) • Clear, technically sound feedback = meaningful influence
Update Design & Risk Inputs • Don’t wait for the final version to start aligning
Integrate Into Product Roadmaps • Work with R&D, QA/RA, and exec sponsors • Flag projects needing early adaptation
Engage the Right Experts • Join WGs or partner with someone who’s inside () • Stay active – your input now shapes what becomes final
Invest in Training • Get smart now to avoid surprises later

Don’t wait for the FDIS – get involved now or get caught off guard later.

Need help with standards?

We provide support for your design and development process for regulatory submissions.? Eisner Safety Consultants can help by

Assisting with strategic compliance planning for your medical electrical product lines,
Providing regulatory support when FDA or a regulator asks technical questions on your submission.
Identification of applicable standards, laws, regulations, guidances, and directives up front to support your design process effectively.
Design Documentation Reviews providing expert analysis supporting the design development process to avoid unnecessary design and development delays.
We provide EU, US, and other countries regulatory requirement reviews of standards, laws, directives, and guidance.
Providing support with Swiss MedDO, EU MDR, clinical evaluation assessment, NB remediation, STEDs, and more.
Interfacing with test houses for medical safety, EMC and arrange other testing.

Feel free to schedule a web meeting with Leo or contact us.

Join me for an Interactive Workshop Identifying Standards, Guidances, & Turn Standards into Your Competitive Advantage @ 10X

leoeisner — Mon, 31 Mar 2025 22:50:00 +0000

Join me, Leo Eisner, The IEC 60601 Guy, as I lead an interactive and fun workshop at the 10X Medical Device Conference in Newport Beach, Ca on May 7 – 8, 2025. Turn Medical Device Standards into Your Competitive Advantage, and discover practical strategies to leverage standards, avoid costly errors, and accelerate your product development cycle.

Don’t make the 5 costly mistakes companies make with Medical Device Standards. Learn from the IEC 60601 Guy himself.:

Late Identification of Applicable Standards: Leads to expensive redesigns and delayed timelines
Ignoring Expert Standards Guidance: Results in regulatory rejections and costly resubmissions
Unprepared Risk Management File for Testing: Risks unnecessary costs due to lack of strategic planning for compliance.
Unprepared Regulatory Submissions: Leads to costly setbacks and market-entry delays
Underestimating Education and Training: Creates knowledge gaps, increasing errors and compliance risks.

I want to thank Sean Smith and his team from 10X for all his help and dedication for putting on this event. He is doing an amazing job and please contact him if you are interested.

Need help with standards?

We provide support for your design and development process for regulatory submissions.? Eisner Safety Consultants can help by

Assisting with strategic compliance planning for your medical electrical product lines,
Providing regulatory support when FDA or a regulator asks technical questions on your submission.
Identification of applicable standards, laws, regulations, guidances, and directives up front to support your design process effectively.
Design Documentation Reviews providing expert analysis supporting the design development process to avoid unnecessary design and development delays.
We provide EU, US, and other countries regulatory requirement reviews of standards, laws, directives, and guidance.
Providing support with Swiss MedDO, EU MDR, clinical evaluation assessment, NB remediation, STEDs, and more.
Interfacing with test houses for medical safety, EMC and arrange other testing.

Feel free to schedule a web meeting with Leo or contact us.

ISO 20417, 2nd DIS Breaking News from Tokyo Meeting 📣📣

leoeisner — Tue, 25 Mar 2025 20:38:12 +0000

ISO TC 210 WG2 met in Tokyo, Japan on 4 – 5 March 2025.

WG2 meeting focused primarily on resolving the National Committees (NCs) comments received on the ISO/DIS 20417, 2^nd ed.

Thx to the hard work of our fearless Project Leader, doing a huge amount of prep work just prior to the WG meeting.
WG was able to review and resolve all the comments.
Next step will be to circulate for FDIS ballot ISO/FDIS 20417, 2^nd ed., that the NCs will vote on.

Changes proposed:

Add reference to transport and storage symbols for environmental conditions for packaging to distinguish between transport and storage environmental conditions.

Updated sub-cl 6.5.3 a) new sub items 2) & 3) with symbols for transport and storage – Special Section not included in LinkedIn Post
These symbols for transport is Symbol 3869 from ISO 14617-14:2004 (link goes to the ISO online browsing platform) and for storage is Symbol 2066 from ISO 14617-7:2002
This has been something I have been developing for more than a year with TC 210/ WG3 and also IEC 60601-1, 4^th ed., IEC TC 62/SC 62A/WG38 with a small team. At the Tokyo meeting TC210 / WG3 we have set up a task team to look at the proposed symbols for transport, storage and operation (operation was not included in ISO 20417 as no comment was provided). WG3 task team has not met yet so unable to share the proposed symbols from WG3 perspective at this time.

IEC TC 62/SC 62A/WG38, Fragment 2, (IEC 60601-1, 4th ed. – learn more about it) 62A/1630/CD was issued Dec 6 2024 and was closed for comments on Feb 28 2025. We are meeting in Arlington, Virginia at the AAMI offices to work on the comments March 30 – April 4, 2025. The two symbols above are part of the symbols that are in the CD and there are additional ones including one for operating IEC 60417‑6090:2012 and transient IEC 60417-5184:2002 environmental conditions, and indoor use IEC 60417-5957:2004. Some combination of the environmental conditions such as temperature, humdity, and atmospheric pressure will need to be combined as applicable to operation, storage and transport. Trainsient is a special condition. Please refer to the CD to understand the usage of the symbols.

Deleted 6.1.2 d) 1) (Change from “EC Rep” to “XX Rep”)

Align with update of ISO 15223-1:2021/A1:2025 published March 3, 2025 with “EC Rep” changed to “XX Rep” (5.1.2).
6.1.2 d) 1) previously stated: “When using symbol 5.1.2 from ISO 15223-1:—, the ‘EC’ may be replaced by the 2-letter or 3-letter country code given in ISO 3166-1.”

Added concept of “applicable policy”

New 3.3 definition.
Aligns with 1/2634/CDV of IEC 60050-880, 1^st ed, term 880-17-02) & about 20 additions in the normative text to “applicable policy” making those requirements based on what the authority having jurisdiction requires so more flexible.

Changed from “production control” to “production control identifier”

Make clearer the definitions of lot number, lot code, batch code, batch number, serial number, & other options noted in 5.9 of ISO 20417, 1^st ed. (will be 5.8 ISO 20417, 2^nd ed.)

The requirements related to commercial product name were deleted as they were duplicative of the catalogue number requirements.

Deleted 4 b)

The previous 4 b) roughly says: Normatively referenced edition of a standard in ISO 20417, ed., the manufacturer may substitute with a more current version provided by the manufacturer provided they can demonstrate the residual risk remains acceptable and is comparable to the residual risk that results from applying the normatively referenced document.
The normative referenced standards in the new draft FDIS are undated or dated. Undated references are required to be the most recent copy of the standard and the dated ones are required to be the dated version. ISO 15223-1 is the only dated normative referenced standard and references ISO 15223-1:2021 and ISO 15223-1:2021/AMD 1:2025 (ISO format requirements) in the draft FDIS.

HAS Consultant comments received late, added to collated comments, and resolved. JTC3 will prepare updated Annex Zs for addition to the FDIS

updated the normative references

Informative referenced standards (“should ” or “see standards” statement) were moved to the bibliography
Dropped ISO 16142-1 & -2 standards as both were withdrawn

Delete former informative Annexes D, F, G and H;

Annex D – Cross reference between the document and the requirements considered
Annex F – Reference to the essential principles (ISO 16142-1:2016 & ISO 16142-2:2017 – both withdrawn)
Annex G – Reference to the general safety and performance requirements for medical devices (Was previous corresponding list of GSPRs to the EU MDR list but will be replaced by Annex ZA^#)
Annex H – Reference to the general safety and performance requirements for IVD medical devices (Was previous corresponding list of GSPRs to the EU IVDR list but will be replaced by Annex ZB^#)
^# Annex ZA & ZB The FDIS will include Annex ZA & ZB prepared by JTC3 but not the final ISO publication.

Need Help?

Need help with 60601 series standards including EMC? Eisner Safety Consultants can assist with strategic compliance planning for your medical electrical product lines, provide support when FDA or a regulator asks questions for a submission. We deal with EU, US, and other country regulatory requirements, standards, laws, directives, and guidances. Our team also provides support with Swiss MedDO, EU MDR, clinical evaluation assessment, NB remediation, STEDs, and more. We work with many test labs for medical safety, EMC and can arrange other testing, as well. Feel free to schedule a web meeting with Leo or contact us.

10x Humanizing MedTech: Breaking The Mould For Conferences

leoeisner — Tue, 11 Feb 2025 06:39:03 +0000

Join us for the fifteenth 10x Medical Device Conference on May 7 to 8, 2025 – Hyatt Regency Newport Beach, CA

What’s 10x 2025 about you ask?

The focus is on building meaningful relationships and tackling real challenges
Move through key stages of the MedTech lifecycle. Each workshop station focuses on critical topics such as:
- Regulatory Pathways
- Cybersecurity
- Engineering
- Product Development
- Market Access
- Reimbursement
- Commercialization

Join experts Carrie Britton, Matthias Fink, Sean Smith, Jan Gates, Angelina Lisandrelli, Jose Bohorquez, and others experts for a journey through the MedTech lifecycle – from ideation to marketed product. Each workshop represents a stage of this journey, offering opportunities to collaborate, ask questions, and exchange expertise.

Thank you, Sean for including me on this impressive list of experts for 10x this year!

Looking forward to seeing you in Newport Beach, CA. – Seats are limited

Join us for this very personalized experience and Joe Hage‘s Ice Cream Social